Confluence Technologies Inc. and its subsidiaries (collectively “Confluence”) is committed to respecting the privacy rights of individuals.

This Privacy Statement ("Statement") sets out how we collect, use, and share your Personal Information and describes how we handle your Personal Information before, during and after your relationship with us. This Statement also explains how we comply with data protection law and the choices available to you regarding collection, use, access to, and how to update and correct your Personal Information.

This Statement applies to you if we process your personal information and you are not an employee of Confluence or an individual to whom we have provided a specific privacy notice. You may for example be an individual that works at a supplier of Confluence or another organization that we deal with, a customer of one of our customers’ employees, a prospective employee, a user of our website or someone who is affected by our activities.

References to you, your, and yourself in this privacy notice are to either you as an individual or any organization that you work for.

For the purposes of data protection Confluence Technologies Inc. will be the controller of any of your personal information. If any other part of our group is the controller of your personal information you will be notified at the time we collect your personal information. This statement will also apply to our group companies

The Personal Information we collect

We may collect the following types of personal information about you:

• Contact details: including information that allows us to identify and contact you directly such as your name, address, email address, and telephone number.
• Identification information: including passport and other official identification details, company information, national insurance number, membership of relevant schemes.
• Details of your work history: including positions, roles, responsibilities, professional qualifications.
• Personal history and information: including hobbies, interests, marital status, family details and dietary requirements.
• Other information provided as a prospective employee during the recruitment process: including education and qualifications.
• Advisors appointed by you: including lawyers and financial advisors.
• Business information: including organization details (e.g. place of work, job title, organization contacts information), billing, payment or banking details.
• Responses to surveys, competitions and promotions: including records of any surveys you respond to or your entry into any competition or promotion we run.
• Creditworthiness: We may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you or the organization you work for.
• Details of your performance: when working with or for us or in relation to any project or work we are engaged in.
• How you use our website: including the pages you look at and how you use them, usernames and passwords.
• Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.
• CCTV images: if you visit any of our premises, some areas may be covered by CCTV or similar system.
• Your usage of the IT systems we make available to visitors to our premises: for example our guest internet and Wi-Fi facilities.
• Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: including letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
• Subscription information: including when you subscribe to one of our blogs or other materials.
• Technical information: including the Internet Protocol (IP) address used to connect your computer to the Internet, source domain names, browser type and version, time zone setting, length of time spent, and operating system and platform.
• Information about your visit: even if you have not created an account or logged in, including the full Uniform Resource Locators (URL), specific web pages, clickstream to, through and from our site including date and time, products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, and any phone number used to call our customer service number.

Special Categories of Personal Information and Criminal Convictions

We may collect, store and use the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• information about your trade union memberships;
• information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
• biometric information about you, for example your height and weight.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

There are limited situations in which we may collect, store and use any criminal records information in relation to you. If we do collect any criminal records information, we will do so on the basis of legal obligations or based on your explicit consent.

Sources we collect your Personal Information from

We will collect personal information from a number of sources:

• Directly from you: when you complete forms we provide to you, when we engage with you by phone, email or you communicate with us directly in some other way, or when you make a complaint or claim.
• Our website: provides us with information about how you use it and the devices that you use to connect to our website.
• Our providers of background information: which may include credit reference agencies, AML check provider, Companies House, LinkedIn and other work related web platforms, former employers, referees and employment agencies.
• Your employer or the organization you work for: they may provide us with your name, position contact details and background information about you.
• Our professional advisors: such as lawyers, accountants, financial advisors, consultants and other advisors.
• Your professional advisors: such as lawyers, accountants, financial advisors, consultants and other advisors.
• The Government, local authorities or relevant regulators: to assist with investigations, for example the Information Commissioner's Office or applications to the local authority.

We and third parties we engage may combine information we collect from you over time and across our Website with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

We will also collect additional personal information throughout the period of our relationship with you.

If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

If you are providing information regarding other individuals to us, it is your responsibility that the personal information you communicate to us is up-to-date and accurate.

How we use your Personal Information

The table below describes the main purposes for which we process your personal information, the categories of your personal information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

Purpose	Personal information used	Lawful basis
Carrying out identity and credit checks	Contact details and payment information	We have a legal obligation to undertake identification We also have a legitimate interest in knowing your identity and/or ensuring that we are likely to be paid
Enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties	All the personal information we collect	To enter into and perform contracts with either yourself or the organization that you represent We have a legitimate to properly perform contracts with third parties
Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you or the organization you work for	All the personal information we collect	To perform a contract with you or the organization that you represent We have a legitimate interest to improve the services and/or products we provide To defend, bring or establish legal claims
Maintain and improve our services and/or products	All the personal information we collect	We have a legitimate interest to improve the services and/or products we provide
Data analytics, statistical analysis and other research to help us improve our online services	How you use our website	We have a legitimate interest to improve the online services we provide and user experience
Security of our IT systems	All the personal information we collect	We have a legitimate interest in ensuring the security of our IT systems
Staff training	All the personal information we collect	We have a legitimate interest to improve the products and services we provide
Direct marketing	Contact details and services and products that we have determined may be of interest to you or your organization and/or which you or your organization has purchased in the past	We may ask for your consent to process your data for this purpose, you may revoke your consent at any point Alternatively if you or your organization has purchased similar services or products from us previously we may market similar products or services as a legitimate interest in developing our business Alternatively we have a legitimate interest to carry out marketing for our products and services. You have the right to opt out from such marketing at any time
Holding events	Your contact details, details of attendance, your comments in response forms and dietary requirements and CCTV images	We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We have a legal obligation to comply with health and safety requirements
To comply with our legal obligations	All the personal information we collect	To comply with any legal obligations or requirements
To manage our relationship with you or the organization you work for and to operate and manage our business and internal reporting	All the personal information we collect	We have a legitimate interest to operate our business in an efficient way and to expand our business To enter into and perform contracts with either yourself or the organization that you represent
Storage of records relating to you and also records relating to our business	All the personal information we collect	To manage and fulfill any contract with you, we may have a legal obligation to do so We have a legitimate interest to keep proper records We have a legal obligation to retain and store certain records
Making a decision about your recruitment or appointment, managing the recruitment process and/or determining the terms on which you work for us	Your contact details, identification information, details of your work history, personal history and information, other information provided during the recruitment process, the correspondence you send and receive from us, special category data	We have a legitimate interest in performing and administering the recruitment process This may be necessary to enter into and manage and perform a contract with you To comply with any legal obligations and requirements
Making a decision about your recruitment or appointment, managing the recruitment process and/or determining the terms on which you work for us	Special category information	Where there is a substantial public interest. To establish, exercise or defend of claims To carry out obligations and exercise our or your rights in the field of employment and social security Based on your explicit consent
Making a decision about your recruitment or appointment, managing the recruitment process and/or determining the terms on which you work for us	Criminal conviction information	To comply with legal obligations or with your consent

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organization you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organization you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we process that information on a basis other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymize and aggregate any of the personal information we hold (so that it does not directly identify you and ceases to be your personal information). We may use anonymized and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

How we share your Personal Information

We may share your personal Information with the following third parties, in some cases located outside of the European Economic Area (the “EEA”):

• Organizations in the same group as us: for purposes of data processing or storage we may share your personal information with our affiliated companies, including StatPro Group Limited (“StatPro”) and StatPro’s affiliates and subsidiaries.
• Other companies in our supply chain: including business partners, service vendors, authorized third-party agents, or contractors to provide our products and services or facilitate transactions. Examples include, but are not limited to: processing work orders, hosting websites and providing support.
• Credit reference and other identification agencies: so that we can assess your creditworthiness and to verify your identity. These agencies may retain a footprint that a search has been undertaken.
• Recruitment agencies or consultants: for the purpose of managing the recruitment process.
• Third parties who ask for or want referrals: we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.
• Marketing and public relations companies: to help us to develop, carry out and assess marketing and PR campaigns.
• Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial or other advice and generally help us deliver our products and services to you or the organization that you represent or for us to purchase them from you or the organization you represent.
• Information providers: including credit reference agencies, money laundering check provider and Companies House.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
• Law enforcement officials, government authorities, or other third parties: as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of Confluence, its business partners, you, or others; or as otherwise required by applicable law.
• Competent authorities: if we believe disclosure is in accordance with, or is otherwise required by or desirable with reference to, any applicable law, regulation or legal process.
• In aggregated, anonymized, and/or de-identified form: that cannot be used to identify you.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

Direct Marketing

For direct marketing purposes, we may share your personal information with StatPro and StatPro’s affiliates and subsidiaries.

From time to time, we or StatPro may contact you by email, post or SMS with information about products or services we believe you may be interested in.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at confluence_privacy@confluence.com. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.

Cookies

Our Website uses cookies to keep track of your visit and to help navigate between sections. A cookie is a small data file that certain websites store on your computer’s hard drive when you visit such websites. Cookies contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is your IP address and information you have personally supplied.

We use cookies on our Website to enable us to deliver content that is specific to your interests and gives us an idea of which parts of our Website you are visiting and to recognize you when you return to our Website. Reading cookies does not give us access to other information on your computer’s hard-drive and our Website will not read cookies created by other websites that you have visited.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Website or certain aspects of our website may not function correctly. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access our Website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/

Please note that providers of third-party content may also use cookies over which we have no control.

Below are examples of the categories of cookies set by our Website, https://www.confluence.com, as well as our blog website, https://blog.confluence.com (collectively referred to hereafter as “Website”):

• Necessary cookies help make our Website usable by enabling basic functions like page navigation and access to secure areas of the website. Our Website cannot function properly without these cookies.
• Statistics cookies help collect information about how our visitors use or interact with our Website, such as the websites the user came from, the number of times and the dates each user visits our Website, the duration a user stays on our Website, the search engine used, what link was clicked and what search term was used. This data is collected anonymously and is used to help improve our Website’s functionality. Statistical cookies may be set by us or by third-party providers whose services we have added to our pages.
• Marketing or targeting cookies help track anonymous user activity, such as IP address, geographical location, visited websites, and what ads the user has clicked with the purpose of optimizing ad displays based on the user’s movement on websites that use the same network. For some of these cookies, tracking is performed anonymously until a user identifies himself/herself, for example, by submitting a form. Please note that third-parties may store targeting or advertising cookies on our Website.

Links to third-parties’ websites

The Website may contain links to third-party websites as a service for you. These third-party websites are operated by companies outside of our control, and your activities on those third-party websites will be governed by the policies and procedures of those third parties. Confluence takes no responsibility for the content or information practices of such third parties and encourage you to review the privacy polices of these third parties before disclosing any information.

Security of Your Personal Information

The security of your personal information is important to us. We implement reasonable physical, administrative, and technical safeguards designed to protect your Personal Information from loss, theft, misuse, alteration or unauthorized access, use, or disclosure. Confluence also relies on reasonable measures to safeguard Personal Information in our possession, including:

• Enforcement of companywide policies and procedures for our employees on how to handle personal information;
• Restricting access to personal information to only those employees and third-party service providers on a “need to know” basis or where access is needed for a legitimate business purpose;
• Use of technologies to safeguard data during transmission, such as SSL encryption for some of the data that you provide via our Website and using appropriate security measures to safeguard the data we collect and possess;
• Use of industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our computer systems and networks.

The internet and our systems, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide us through this technology or other means. Should we become aware of any breach to the security and confidentiality of your personal information, and where required by law, we will inform you without undue delay.

Transferring your personal information internationally

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third party processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws. For further details please contact us by using the details set out in the “Contacting us” section below.

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

As a global organization with legal entities and business processes in operation across borders we may transfer your personal information to Confluence in the United States of America, to any Confluence subsidiary worldwide, or to third parties and business partners as described above that are located in various countries around the world. By using our websites or providing any personal information to us, where applicable law permits, you are informed of the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below

Retention of Personal Information

We will retain your personal information as needed to fulfill the purposes for which it is collected. We will retain and use your Personal Information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. We have set out below the main retention periods which will apply:

• For individual contacts at customers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 10 years afterwards.
• For individual contacts at suppliers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 8 years afterwards.
• For individuals making complaints and/or claims it will generally be a period of 10 years after resolution of the relevant complaint and/or claim.
• For prospective employees (who do not become employees) the longer of 2 years form the date of the record’s creation or 2 years from the date of the decision not to hire.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organization or change your phone number or email address you can contact us by using the details set out below.

 Your Rights

You have the right to be informed about how your personal information is being used, access, obtain a paper or electronic copy, review, correct and update all your personal information stored by us to confirm its accuracy. You may request that certain of your personal information be deleted from our files. You may have the right to restrict or object to the processing of your personal information. In certain circumstances, when required by applicable law, you may also exercise your right to portability of your personal information. You may also have the right to object to certain automated decision making processes using your personal information. We will make reasonable efforts to comply with such requests, unless such requests are prohibited by law, or there is a legitimate purpose to retain personal information, in which case we will inform you without undue delay.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal information. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We reserve the right to verify your identity before any request relating to your personal information processed by us. To exercise any of the above rights, or if you have any questions relating to your rights, please direct any questions about your personal information to confluence_privacy@confluence.com.

If you are not satisfied with our answer or the way we process your personal information pursuant to this Statement, you may also have the right to lodge a complaint with the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

Children’s Privacy

Confluence encourages parents and guardians to take an active role in their children's online activities. Confluence does not sell or offer its services and products to children. As such, our sites are designed for adult user interaction. We do not intentionally collect personally identifiable information from children under the age of 18. If you are a parent or legal guardian of a minor under the age of 18 and believe that the minor has disclosed personal information to us, please contact us.

Updates

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date and will try and give you reasonable notice unless we are prevented from doing so. Where we are required by law we will seek your consent to changes in the way we use your personal information. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.